Subject: File No. S7-14-08
From: Nancy Huseman
Affiliation: Insurance and Securities Agent

September 6, 2008

Sirs
I am absolutely opposed to this ruling.
Index annuities are guaranteed products and the client absolutely does not lose one penny. There is absolutely no risk involved.
I am sure the SEC wants this rule only for their self interest. Understand, securities licensed brokers and agents do not reccommend annuities to clients for the reason that an annuity is a long term investment, and is guaranteed. Clients have to request it. Understand, when money is in annuity, the money is tied up for a longer term which means it is not available for trading. Understand securities brokers and agents make their money on trades and have to do many trades to make a living.
I am sure if you would poll all investment accounts with the brokerage house, you will find the percentage of the money that is annuities (primarily variable annuities / which is still risk), it would be a very low-low-low percentage. I have been in this business over 20 years, brokerage houses and thier agents do not like annuities for the above reasons.
Brokerage houses have seen money move from the brokerage account to index annuities because of the security and guarantees this is just a strategy to try to prevent the movement of money from an UNGUARANTEED ACCOUNT TO A GUARANTEED ACCOUNT.
In my 20 years of experience, I have not seen a brokerage statment where the brokers have put a client in a guaranteed annuity (such as an index annuity). When the client wants less risk and some guaranteed, the brokerage house always reccommends a variable annuity (no guaranteed - only the principal at the time of death.
If the brokerage house was truly interested in the clients,
the brokerage houses would have reccommend the index annuity to their clients long ago, but the brokerage house does not and will not in the future for the above reasons. Their is no need for a securities license as this product has NO RISK. I certainly hope you gentlemen have taken time to examine the index annuity and understand how it works and the guarantees.
Brokerage houses and securities agents have a mind-set that trade and risk is the only way to invest and make money. NOT TRUE